Reach And You

Welcome to REACH at Lucite International

The new regulation will come into force on 1st June 2007 and presents a massive challenge to the EU chemicals industry.  As preparations for REACH are underway the aim of this blog is to provide information on the status within Lucite International and support for both customers and suppliers.

Presentation to REACH Ready/NEPIC workshop

Presentation given at NEPIC conference 21st March 2007.

Download reachready_nepic_presentation.ppt

REACH - The view from Lucite International

At Lucite International we have been preparing for the introduction of REACH since 1998. Our preparations have involved working closely alongside trade associations in Europe, the USA and Japan to track developments and to ensure that we fully understand the implications for both our raw materials and the products we sell. Here, we share our understanding, and explain what REACH will mean for LI and our partners in the supply chain.

Responsibility lies with manufacturers and importers

In a nutshell, REACH will provide a single, standardised framework for the safe management of chemicals within the EU. It places responsibility on manufacturers, like ourselves, and importers to ensure that the substances, in quantities greater than 1 tonne per year, do not adversely affect human health or the environment. A core part of this responsibility requires industry to provide comprehensive documented information for all qualifying substances. The availability of this transparent and uniform information will enable users to assess potential risks and ensure adequate controls are in place. It will also create a robust platform from which the industry can innovate and grow safely in the world arena.

Registering chemicals and use scenarios

In the first instance, chemicals must be pre-registered to take advantage of the phased introduction of the regulation. The next step is to prepare use scenarios and to assess the exposure associated with the use of the individual substances against given toxicology data. Development of use scenarios will mean close collaboration with customers to fully understand how a substance progresses through the supply chain and how it is placed on the market. This is also key to ensuring that all uses for products are included in the final registration dossier. LI is already engaged with its customers in this respect to try and understand how this may work. Once assessed and approved, uses will all be summarised on the safety data sheet for that chemical and any restrictions highlighted. If a data sheet does not cover a particular application, then there is an obligation for the user to review that with the supplier to get it included and the registration updated or to register it separately if they wish to keep it confidential

Preparations underway at LI

To date, a substantial amount of work has been done with suppliers to ensure that key raw materials will be supported and that LI’s manufacturing processes will not be affected. As part of this work, our business systems are being upgraded to ensure that we will be able to demonstrate that the materials we purchase are registered for our own and, where appropriate, our customer uses, and that our products are fully registered for customers needs.

Dates, weights and special concern product

The deadline for registration is phased according to the quantity of the substances being manufactured or imported. Chemicals of 1000 tonnes or more per year (which includes methylmethacrylate), or those of highest concern, must be registered by December 2010. Substances 100-1000 tonnes per annum must be registered by June 2013, and all substances of 1 tonne or above must be registered by June 2018. REACH may also require authorisation for manufacture or use of substances of highest concern. These are cancer-forming chemicals (category 1 or 2 carcinogens or mutagens), chemicals hazardous to reproduction (reprotoxins) or substances with high environmental impact (either persistent, bio-accumulative and toxic or very persistent and very bio-accumulative). The commission will develop and manage the list and authorise the use of these chemicals on a case-by-case basis.

Dedicated resource

In recognition of the wide-ranging impact REACH will have across our business, LI has established a multi-disciplined project team to handle both the strategic and day-to-day management of the changes that must be made to ensure compliance with the new legislation. Sponsored by the Company’s Executive, the REACH team draws on the knowledge and experience of people from each of our manufacturing sites as well as purchasing and sales. The team is there to provide practical help and advice both internally to colleagues and externally to customers, partners and suppliers on any issue relating to REACH.

Find out more about the legislation and its implications for your business in FREFLOW REACH, our new mini guide that can be downloaded from this site or follow the useful links to other authorities. For more specific details on LI’s approach, please contact Fiona Smith at: reach.info@lucite.com

Transition to REACH 24th April

REACHReady are running a workshop on 24th April in York. 

Download transition_to_reach_workshop_24_april_20071.pdf

For details click on this link (REACHReady) to go to the REACHReady website.

REACH Text Translations

The REACH text will be available in official languages of EU Member States on the eur-lex website.

The direct link is pasted below:

http://europa.eu.int/eur-lex/lex/JOHtml.do?textfield2=396&year=2006&Submit=Search&serie=L

Registration Requirements for EU Manufactured Products

Registration requirements for products placed on the market are dependent upon how that product is defined under REACH i.e. substance, article, polymer, preparation, intermediate.

For products manufactured in the EU we have pulled together the attached chart that enables a check of the definition against the requirements.  This is pasted from the text of the legislation, although there is some assessment for our products included.  It is a powerpoint file that allows access as read-only.

There are slight differences for products manufactured outside the EU and imported and hence this slide only applies to EU manufactured materials.

Download reach_requirements_for_eu_products.ppt

Competent Authority REACH Conferences

The UK Competent Authority (HSE) is running a series of national conferences aimed at raising REACH awareness.  The first of these was the English conference, held at Leeds on 5th September, but others are planned for later in the year.  In addition they are planning to hold a number of regional roadshows.

Details of these events are available at the HSE website, or follow the link below:

http://www.hse.gov.uk/reach/diary.htm

Lucite International supported the English conference with a presentaion highlighting some of the issues we see associated with communications through the supply chain.  A copy of the presentation slides from this is attached below:

Download presentation_for_ca_workshop_2.pdf

Lucite International Business Guidance Documents

The impact assessment of REACH at Lucite International led to the development of our generic reference booklets (available in the download section on this blog) but also more specific business area assessments that have been used internally.  However, we recognise our partners in the supply chain may handle materials and products in similar ways and we have converted these documents to .pdf format to allow them to be shared.  The link below will take you to an overview page giving a schematic of a global monomer, polymer and acrylic sheet production.  Attachments to each of the product types will open the LI REACH impact and preparation assessment for that specific production area which we hope may be of interest.

LI REACH Business Specific Guidance Document

Lucite International Monomer Pre-registration

Lucite International Monomers have been pre-registered at volumes to cover material that we manufacture or import into the EU and that which downstream users could import into the EU, either directly or as part of a polymer structure.  The pre-registration numbers for each region are detailed below:

Substance	Origin	Pre-registration Number
Methyl Methacrylate	Lucite International UK	05-2114129608-45-0000
	Lucite International USA	05-2114131521-65-0000
	Lucite International China	05-2114131532-62-0000
	Lucite International Singapore	05-2114131528-51-0000
	KMC	05-2114131531-64-0000
Methacrylic Acid	Lucite International UK	05-2114129608-45-0000
	Lucite International USA	05-2114131526-55-0000
n Butyl Methacrylate	Lucite International UK	05-2114129606-49-0000
	Lucite InternationalI USA	05-2114131522-63-0000
i Butyl Methacrylate	Lucite International USA	05-2114131523-61-0000
Ethyl Methacrylate	Lucite International USA	05-2114131524-59-0000
2-Ethyl Hexyl Methacrylate	Lucite International USA	05-2114131525-57-0000

Lucite International Resin Pre-registration

Lucite International has pre-registered the qualifying components of Lucite®,Colacryl® and Elvacite® resin grades manufactured in the UK. Netherlands and USA.  These pre-registrations cover monomers and chemically bound substances at greater than 2% and 1tpa in these products.